Reasonable opportunity in GST assessment leads to remand for fresh adjudication after conditional deposit.

The Madras HC set aside a GST assessment where the taxpayer had not effectively received notice beyond portal uploads and had been denied a meaningful chance to respond. It held that the interests of justice justified remand so the demand could be reconsidered on merits after a reasonable opportunity, including a personal hearing. To protect revenue, the court made remand conditional on deposit of a portion of the disputed demand, and directed fresh adjudication thereafter.

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Issues: Whether the assessment order confirming the GST demand was liable to be set aside for want of a reasonable opportunity and whether the matter should be remitted for fresh consideration.

Analysis: The assessment was challenged on the ground that the petitioner was not aware of the proceedings, as the notices and communications were uploaded on the GST portal without effective communication by other modes. The record showed that the tax proposal had been confirmed because no reply or supporting documents were filed, but the petitioner sought an to contest the demand on merits. In the circumstances, the interest of justice warranted granting a further opportunity, while safeguarding the revenue by directing payment of a portion of the disputed demand as a condition for remand.

Conclusion: The assessment order was set aside and the matter was remitted for fresh adjudication after providing the petitioner a reasonable opportunity, including a personal hearing, upon compliance with the directed deposit condition.

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